Worldwide transfer pricing reference guide 2014

Oman
Taxing authority and tax law
Taxing authority: Secretariat General for Taxation (SGT), a part of the Ministry of Finance, is the body authorized to regulate
transfer pricing.
Tax law: The Income Tax Law (ITL) is issued by the Royal Decree 28/2009 and the Executive Regulations, clarifying certain provisions of
the ITL, are issued by Ministerial Decision 30/2012. All tax legislation is enacted by the Royal Decree. Provisions that implement the tax
law are introduced by Ministerial Decisions and Executive Regulations.
Relevant regulations and rulings
Articles 126 to 128 of the ITL contain the transfer pricing regulations.
OECD guidelines treatment
The OECD Guidelines are not binding for Oman. However, the tax authorities in the past have taken the OECD Guidelines into account.
Priorities/pricing methods
No pricing methods have been prescribed in the law or under the existing regulations. The law mentions that the pricing shall be taken
into account, assuming the terms on which the transactions would have been entered into by independent persons. This suggests the
CUP method. It is expected that the tax authorities will enact more rules and publish more guidance in the coming years.
Transfer pricing penalties
There is currently no specific transfer pricing penalty prescribed in the law.
Penalty relief
As there are no specific transfer pricing penalties, no penalty relief is currently applicable. While there are no specific provisions for
relief, the tax department does look at each case independently and has, in the past, waived the delay penalty on late submissions of
tax returns.
Documentation requirements
The law has not provided any specific documentation requirements. Therefore, documentation requirements are determined on a
case to case basis.
Documentation deadlines
As no documentation requirements have been provided, no documentation deadlines are currently applicable.
Statute of limitations on transfer pricing assessments
There are no separate transfer pricing assessments conducted in Oman. The transfer pricing assessment will be conducted as a part of
the regular tax assessment for a tax year. The statute of limitations to complete the regular tax assessment is five years from the end of
the year in which a tax return is submitted.
Return disclosures/related party disclosures
Oman follows International Financial Reporting Standards (IFRS). Therefore, the SGT expects the taxpayer to disclose the related party
transactions in their financial statements in accordance with the IFRS.
Transfer pricing-specific returns
Under the new Executive regulations which were issued in 2012 the tax return has been modified to provide information by the taxpayer
on related party transactions. The disclosure requirement was effective from 2012.
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